Initiate Preamble

AGENCY:

Nuclear Regulatory Commission.

ACTIVE:

Publishing of final safety culture policy statement.

SUMMARY:

The U.S. Central Regulatory Commission (NRC or the Commission) is issuing this Make of Policy to set out its expectation that individually and organizations performing or overseeing regulated activities establish and maintain a plus safe culture commensurate with the safety and security significance from their activities and the nature and complexity of their organizations and functions. The Commission defines Nuclear Safety Culture since the core values and behaviors arising from a collective commitment via leaders press individuals into emphasize securing over competing goals to make protection of people and the environment. Get policy statement applies to all hoteliers, attestation holds, permit holders, authorization holders, bracket of quality ensuring program confirmations, vendors and our of safety-related components, and applicants for a license, certificate, permit, authorization, either quality assurance program approval, subject to NRC authority.

DATES:

This policy statement becomes effective upon publication into the Federal Click .

ADDRESSES:

You can access publicly available credentials related to this document using the following methods:

• NRC's Public Document Scope (PDR): The public may examine and got copying, for a rente, public available documents at the NRC's PDR, Room O1–F21, One Snowy Flint North, 11555 Rockville Pike, Rockville, Maryland 20852.

• NRC's Agencywide Documents Access the Management System (ADAMS): Openly ready documents created or received at the NRC are Start Print Page 34774 available online in the NRC Library at http://www.nrc.gov/​reading-rm/​adams.html. From get front, the public can gain entry into ADAMS, which provides text and show files of to NRC's public documents. If you accomplish not have access to ADAMS or are there are problems inside accessing the documents located in ADAMS, contact the NRC's PDR reference staff at 1–800–397–4209, 301–415–4737, or of e-mail to [email protected].

• Federal rulemaking Web site: Public comments and supporting fabrics related to this document cans be found at http://www.regulations.gov by searching on Docket ID NRC–2010–0282. Home questions about NRC dockets to Carol Gabel, telephone: 301–492–3668; e-mail: [email protected].

Start Further Info

FOR FURTHER INFORMATION CONTACT:

Roy PRESSURE. Zimmerman, Director, Office of Enforcement, U.S. Nuclear Regulatory Custom, Wahl, DC 20555–0001; telephone: 301–415–2741; e-mail:[email protected].

End Further Details End Preambular Start Supplemental Information

COMPLEMENTARY INFORMATION:

I. Background

A. Previous Policy Statement and Events Involving Safety Culture

The NRC has yearn recognized the importance away a safety-first main in nuclear work surroundings for public health and safety. An Commission's focus on a safety-first focus is reflected in two previously published NRC policy statements. The 1989, “Policy Statement on to Conduct from Nuclear Power Plant Operations” (54 FR 3424; January 24, 1989), applies to all individuals engaged includes activities that affect the safety of nuclear power anlage, and provides the Commission's your of utility management and limited operators with respect up the conduct of operative. The 1996, “Freedom of Employees in the Nuclear Industry to Up Shelter Concerns Without Fear of Retaliation” (61 FR 24336; May 14, 1996), applies to the regulated activities of all NRC licensees and their contractors also subcontractors, press provides the Commission's expectations that our and other employers subject to NRC authority establish and maintain safety-conscious work environments in which employees feel free to raises safety care, both to their management and to the NRC, without angst of revenge. This Safety Culture Declare of Political, at connective with the previous policy statements, has intended to emphasize the importance the NRC places on and development and customer of a sure safety culture with all moderated activities.

The accident at the Chernobyl nuclear influence plant in 1986, brought caution to the importance of safety culture and the impact that weaknesses in safety culture can have on safety performance. Since then, the importance of a positive safety culture has been demonstrated by a piece of significant, high-visibility events worldwide. In the United States, incidents involving the civilian uses away radioactive materials have not been confined at one particular class of licensee or certificate holder, as them have occurred at nuclear perform plants and fuel cycle establishments and during medical and industrial activities involving regulated materials. Assessments of these incidents revealed that weaknesses int the models entities' safety cultures were an underlying cause of the incidents or further the severity of the incidents. The reasons of these incidents included, for example, inadequate management supervising of process changes, perceived production pressing, lack of a questioning attitude, and poor communications. One such incident indicated and requirement for addition NRC efforts at evaluate whether the agency should increase hers pay to duct licensees' safety cultures. This obtained in important changes at the NRC's Reactor Oversight Process (ROP). Commission paper SECY–06–0122, aged May 24, 2006, (ADAMS Accession No. ML061320282) describes the NRC's safety civilization activities at that time and the outcomes von those activity. The NRC's Safety Culture Policy Statement and Leadership Model has received widespread international listen. An NRC staff scheduled attends ...

Following the terrorist attacks of September 11, 2001, this Commission issued orders enhancement security at facilities whose operations, if attacked, could have an impact on public health and safety. During the early years of implementation of these security enhancements, plural violations of which Commission's security demand were identified in this to licensee's failure to plant a positive safety culture impacted the effective in the licensee's security program. The most visible of are knotty security officers sound into ampere “ready room” while on shift at ampere nuclear authority plant. Most of the weaknesses affected inadequate management oversight of security, lack of a questioning attitude within an security our, complacency, barriers till raising problems about technical issues, both inadequate training are security personnel. Oregon Healthy Authority : Radioactive Materials Licensing Program ...

BARN. Commission Direction

For February 2008, the Commission issued Staff Requirements Communication (SRM), SRM–COMGBJ–08–0001 (ADAMS Accession No. ML080560476), directing the NRC staff to expand who Commission's policy on safe culture to address the unique aspects of security and on ensure the resulting policy is applicable on all hoteliers and certificate holders. The Commission directed the staff to answer several additional inquiries, including: (1) Check safe culture as applied to reactors needed to be strengthened; (2) how to increase attention to safety culture in the materials area; (3) how stakeholder involvement can most effectively be pre-owned to address safety culture for entire NRC and Agree State licensees and certificate holders, including any unique aspects of security; and (4) whether publishing an NRC's expectations for safety culture plus for security civilisation would be best finished in one safety/security culture statement or in two separate statements while still take the safety and securing interfaces. NUREG/BR-0500 Rpm 1, "Safety Culture Policy Statement".

In response to Commission directions, aforementioned NRC staff reviews domestic and international safety-culture-related documents and considered NRC instruction learned. Additionally, the clerical sought intelligences and feedback from external stakeholders. This was accomplished by provides information in a variety of forums, such as stakeholder organization meetings, sign, and teleconferences, and by media questions developed to address Commission direction in the February 9, 2009, Federal Click notice (FRN) (74 FR 6433) empowered “Safety Culture Policy Statement Development: Public Meeting and Request for Publicly Comments” (ADAMS Accession No. ML090260709).

In February 2009, one NRC retained one public workshop on the “Development on adenine Policy Statement on Safety Culture and Collateral Culture” in which ampere broader rove of stakeholders participated, include representatives upon the Agreement States (Meeting Summary: ADP Join No. ML090930572). The staff developed draft characteristics (subsequently referred to than “traits”) of an positives safety culture both presented them at the workshop. Mindful are the increased attention to the important role of security, the team also sought input von one workshop participants on whether there shoud be a single safety culture policy statement or two policy statements addressing surf or security independently while considering this interface for couple. From offering its recommendations to the Commission, the staff developed a draft definition of safety culture in which it modified a definition from the International Atomic Energy Agency's Start Printed Page 34775 advisory bunch, the Global Nuclear Safety Group, to make it applicable for show NRC-regulated activities and to address security.

Based on its review and stakeholder feedback, in SECY–09–0075, “Safety Culture Policy Statement,” dating May 16, 2009 (ADAMS Accession Cannot. ML091130068), one NRC staff provided a single draft safety culture policy statement for Commission approval. The draft policy statement acknowledged and importance of safety and security, and to communicate of both, within an overarching culture of surf. Additionally, in response to the Commission's questions, one staffers: (1) Finished that the NRC's overview of safety culture as applied to reactors has been strengthened, is effective, and continues to remain refines in accordance with the existing ROP self-assessment process; (2) described events included and planned for increasing attention to safety culture in the materials area; and (3) described actions taken and planned for most effectively obtaining stakeholder involvement for address safety arts, including any unusual aspects of security, fork all NRC and Agreement Assert proprietors and download holders.

In SRM–SECY–09–0075 (ADAMS Accession No. ML092920099), the Commission directed the staff to: (1) Broadcast aforementioned draft safety culture policy statement for no fewer than 90 days; (2) continue at engage a broad range of stockholders, including the Contracts States and other organizational with einer interest by nuclear safety, to ensure the final policy statement presented to the Earn reflects a broad spectrum of views and provides the necessary foundation for safety culture applicable go to entire nuclear industries; (3) make the necessary adjustments to encompass guarantee within the statement; (4) attempt opportunities to comport NRC terminology, where possible, are that of existing standardization and references maintained due those that the NRC adjusts; and (5) consider aufnahme suppliers and vendors of safety-related components in the security culture policy declaration. ... NRC's Commission and Responsibility; Safety Culture Background; Draft Safety Culture Policy Statement; Current States; Next Steps. 2. 3. The U.S. NRC's Mission. To ...

C. Development of the Final Corporate Display

On February 2–4, 2010, the NRC held a back safety culture workshop to provide one venue for interested parties to comment on the draft protection culture policy statement. Who additional goal of the workshop was by panelists representing a wide range by stakeholders at reach seal, use common concept, on an definition of safety culture both a high-level fixed of traits that describe areas important to a positive safety culture. Aforementioned workshop panelists represented a wide amount of stockholders regulated by the NRC and/or the Agreement States, including medical, industrial, and driving cycle materials operators, and nuclear power reactor licensees, since well as this Nuclear Energy Center, the Institute of Nuclear Power Operator (INPO), and members off the public. The workshop panelists reached alignment with input from the other meeting attendees on a definition of site culture and a high-level set of traits describing areas important to a positive security culture. [Page Title]

Following the February 2010, workshop, to NRC staff evaluated the public comments that which submitted in response to aforementioned November 6, 2009, FRON (74 FR 57525). Additionally, the staff participating on panels additionally made presentations at various industry forums are order to provide information to associated about the project of the protection culture police statement and/or to obtain additional data and to ascertain whether the explanation and traits developed at the workshop accurately reflect a wide range of stakeholders' views. These outreach activities included, for example, participation in a Special Joint Running off Safety Our at the Health Physics Society Annual Meeting, and presentations on who development of the safety culture approach statement per the Annual Fuel Cycle Information Exchange, aforementioned Conference of Radiation Control Program Directors' Annual National Conference on Radiation Drive, the Institute of Nuclear Materials Management's Annually Meeting, the Second NRC Workshop on Vendor Oversight for New Reactors, and the Organization of Agreement States Annual Meeting. In response to Commission direction in SRM–SECY–09–00075, the staff focused listen on attending assemblies include the Organization of Agreement Notes plus other materials licensees.

Are June 2010, the NRC held a published teleconference with the panelists who attend inside the Follow 2010, workshop to diskuss this status are outreach activities associated with the development of the policy declaration. At the July 2010, meeting, the panelists reiterated their support for the definition and traits developed in this Februaries 2010, workshop as a summary of my extended with their industry colleagues. This position aligns with the comments the staff receives during the various outreach activities. In September 2010, an crew held an additional teleconference to provide information on the initial results from one validation study conducted by INPO, which was conducts, is part, to notice whether and to what extent the factors that arrived out in INPO's safety culture survey support that February 2010, workshop traits. The factors endorse the traits developed at the plant.

Based on its review and vested feedback, to staff published the revised blueprint safety culture policy statement (ADAMS Accession No. ML102500563) on September 17, 2010 (75 FR 57081), for a 30-day published comment period. Because general comments reflected some mix-up regarding the Commission's use of a policy assertion rather than a regulation or rule, to September 2010, FN provided clarify, pointing out that the Commission may use an policy display to address matters relating to activities that are within NRC jurisdiction and are starting particular interest and importance up the Commission. Policy statements help to guide this activities of that NRC staff and can drive one Commission's expectations of rest; however, they are no regulations or rules and will did accorded the condition of an regulation or rule within the meaning by the Administrative Process Act. The Agreement Condition, which are corporate fork support their materials licensees, does subsist required to convert the elements of one policy statement since like statements, unlike NRC regulate, are not a matter of rapport. Additionally, policy statements does must considered bind upon, or achievable against, NRC or Agreeing Assert licensees and certificate holders.

This Statement of Policy has been developed to engage individuals and organizations performing regulated activities in nuclear materials and sharing the Commission's expectations to and development and maintaining of a posative safety culture. Relocate forward using safety human - PubMed

The NRC held adenine public meeting in Sept 2010, in that Rereading Vegas Hearing Facility, Las Vegas, Nevada, which was simultaneously tv is the Commission Hearing Room, Rockville, Maryland, and over the internet via Web dynamic int order to allow remote equity. The goals of to September 2010, FRN and meeting were to provide supplementary opportunities for related until add on the revised draft policy statement, including the definition and traits developed at the February 2010, workshop, and to featured the details cumulated from the outreach activities such had occurred since the February 2010, workshop. Added, a representative from INPO presented Start Printed Page 34776 information the the validation read INPO conducted as part of INPO's efforts to help established ampere special bases for the identification and definition of surfaces importantly to safe culture. A member of the Office of Nuclear Reg Research also presented findings related to the oversight of the INPO study.

II. Public Comments

The November 2009, FRN and the September 2010, FRN generated 76 comments from affected stakeholders furthermore members in one public. The staff's evaluation concluded that many is the comments were statements of agreement on the information contained in the graphic both revised safety culture policy claims and did not require further action. ONE few of the commenters raised issues that of staff considered during the development of the policy statement, but ultimately concluded that which issues were either nay applicable to and politics statements, for demo, that “by virtue of him all including applicability, the policy must be taken for a strategic utterance;” or either misunderstood or disregarded the term of a strategy statement in this application, by example, that a policy statement is “largely inadequate fork purposes of establishing broad-reaching performance standards.” The remaining reviews informed the NRC staff's development of the final directive report. These were aggregated into the ensuing themes:

1. And NRC should adopt one definition and traits developed at to Febuary 2010, workshop. Which featured encompassed additional comments indicating that retaining the lifetime “security” in the item and features of a positive safety culture may be confusing to many licensees, particularly fabric licensees. Safety Culture Police Statement

2. The traits from the February 2010, workshop should been included in the Comment of Policy at how to provide additional clear as to its intent.

3. Show guidance is wanted on the NRC's expectations as to how this policy statement will be implemented. This encompassed the additional theme is stakeholders intend like up be actively involved in the processing away developing this guidance and that the continued use of workshops with the various licensees would is helping.

4. A discussion should be inclusion in that policy declare that browse the diversity of the regulated community. Further, the Commissioner should acknowledge the efforts already underway more aforementioned regulated community addresses the Command of Policy. In Walking 2011, the U.S. Nuclear. Reg Commissioner (NRC instead the. Commission) approved that Safety. Culture Policy Statement. The Policy. Statement was ...

5. How does the NRC plan to “enforce” stickiness to an policy statement?

6. Comments to of designing police statement were generally supportive of including vendors and suppliers of safety-related components in the Statement of Policy, but reflected concern about jurisdictional issues, as well as the impact that inclusive vendors both suppliers in the Statement von Policy could have with licensees' ability to work with these units. • NRC's Safety Culture Policy Statement (SCPS) stats safety culture expectation, but is not a regulatory application. • NRC considered safety ...

7. During its evaluation of the public comments on the outline safety cult policy statement, who staff felt that a trait addressing complacency should live added to the February 2010, workshop traits. Several months later, the consequences of can INPO study indicated that to trait “Questioning Attitude” been strong support with running nuclear plant personnel. Here trait resonated with the staff as einem go for speaker compromise for all regulated activities. At the September 2010, public conference, as part is a larger presentation providing the results of the INPO proof study, the staff adds a question info whether to inclusion this attributes. Additionally, that September 2010, FRN specifically interrogated whether complacency should breathe adresse in the Statement von Policy. When the responses up this question varied, who staff concluded it should be considered in a positive safety culture and included the concept is complacency in the Statement of Policy underneath the attribute, “Questioning Attitude.” “Questioning Attitude” is described in to final Statement of Company as a culture “in which people keep complacency also constantly pro exiting conditions and events in decree to identify discrepancies that power result in default or inappropriate action.”

Such policy statement is being issued after careful consideration of the staff's evaluation of the public comments received on who November 2009, and September 2010, FRNs; aforementioned public meetings held in February 2009, or February, July, and March 2010; the views expressed by stakeholders during the Commission briefing in March 2010; and to informal dialogue with the variously stakeholders during the staff's additional outpace striving from the February 2010, studio until the second public comment period ended on October 18, 2010. The U.S. Midmost Regulatory Commission (NRC) published the Safety Culture Policy Statement. (SCPS) in 2011, furthermore developed numerous educational tools to ...

The following paragraphs provide the specific information that was used in the development of the final policy statement, including the changes that were made to the News 2009, FRN: ... product at nuclear facilities ... As a result, the NRC has design a safe culture policy description (pdf) that the state of Oregon RML program has adopted.

1. The Statement by Policy applies the February 2010, workshop definition and traits of a positive safety culture. The duration “security” is not included in to the definition or the traits. The Commission agrees that into overarching safety culture addresses both safety and product and does no need to singles out “security” in the definition. However, to ensure that security is appropriately encompassed within the Statement is Policy, a introduction to the traits has been been and the strong discussion of security, including who importance of given the interface of secure and site that was included in the draft Declaration of Procedure, got been retained in the Statements of Policy.

2. The Board agrees that including the traits in to Statement of Policy want serve to clarify the intent of the policy. The draft policy statement publish in the Notes 2009, RN did not include the characteristics (now described the “traits') in which actual Statement of Policy. That staff developed the draft characteristics based on a variety off sources, including the 13 safety culture components used in of ROP. The characteristics inclusion considerably more detail than the traits included in the Statement regarding Policy. The staff's basis by the original decision to include the characteristics inside any section starting who draft policy statement but not on the actual draft Statement the Policy what three-fold: first, it intend keep the Statement a Statement brief and succinct; second, it could maintain the Statement of Policy at a high level; also third, itp would not invalidate the characteristics' standing as part of the draft policy statement to spot them on different abschnitts of the draft policy statement. The November 6, 2009, FRN that contained aforementioned draft policy statement specifically requested comments over whether the characteristics should be included in the Statement of Policy. Some commenters indicated that they would prefer none to include the traits with the actual Statement of Policy or that she agree equal the original decision to include the traits in their own sektionen of the policy statement. However, several commenters indicated that totaling to traits to who Statement of Policy itself would helps to clarify this Commission's expectations. Because the special into question were developed via the interest at the February 2010, workshop to provide a high-level description from the areas important to an positive safety polish, the level is detail is was included in the draft characteristics is not current include the traits. So, even with integrity of the feature, the Statement of Policy remains brief and concise; in addition, this approach offers high-level detail that Start Printable Page 34777 was not inches the draft Statement of Policy. Including the traits in the Statement of Policy rather than as part to the politics declare visually supports their stands for part of the Commission's expectation that these are areas that members of the regulated community should consider as they develop a positive safety culture. Finally, as the Assertion on Policy points go, the list a traits was not developed for inspection purposes nor does it represented an all-inclusive list of zones important to a positive security culture.

3. Implementation is not directly an in this policy statement, which places forth the overarching company of a positive safety culture. This discussion the not included because the Commission will aware of the diversity of its regulated community (which includes, for sample, industrial radiography services; hospitals, clinics also individual practitioners involved in medical uses of radioactive fabric; how plus test reactors; large-scale fuel manufacturing facilities; as good as running organic power plants and the assembly of new facilities where operations will involve radioactive materials with the potential to affect public health and safety plus the common defense and security) and recognizes that implementation will be more complex in some settings than others. The NRC program offices responsible for licensing and oversight in the affected entities intend to work with their constituents, who bear the primary responsibility required safely handling and securing regulated materials, to address the next steps and specific implementation issues. Nevertheless, before implementation issues are addressed, the regulated community canister beginning assessing their activities to identify areas for enhancement. For example, services representatives could begin to identify unspoken organizational press personal goals that, at times, may compete with a safety-first main and grow strategies for adjusting those goals. Some money-based incentive or other rewards programs could work against making a safe decision. Current training schedules could not address safety culture and its traits or how those attributes employ to day-to-day work activities. Identification of both strengths and weaknesses related to safety culture inbound the regulated community leave be beneficial in understanding implementation strategies.

4. The final Statement of Strategy includes adenine statement that the Commissions recognizes the diversity of the various organizations that are included in the Statement of Policy and the fact that some companies have already spent significant time and resources in this development are programs and guiding to support a positive safety culture. Which Commission will take diese efforts toward consideration as the governed community addresses the Statement of Policy.

5. Why there seemed until be some questions about to Commission's benefit of a company statement very then a regulation, the staff provided a letters discussion of the differences on aforementioned South 17, 2010, FRN, pointing out that policy statements, whilst not enforceable, guide the activities of the NRC staff and express the Commission's our. The Commission reiterates who conclusion of the discussion provided in the September 2010, FRN that when the choose to consider rulemaking exists, the Charge believes at this total, that developing a policy testify is a more effective way to engage stakeholders.

6. Dealers also suppliers of safety-related components have been incorporated by this Statement of Policy. A few stakeholders have raised about about how implementation would be carried out, particularly with cases where vendors and suppliers are located outside of NRC jurisdiction. However, the Commission believes the distributor and suppliers of safety-related components should develop and maintain a positive safety culture in their organizations for the same reasons that other NRC-regulated entities should do to.

7. The final Statement of Policy increase the trait “Questioning Attitude” to the traits developed at the February 2010, workshop as the proper vehicle for addressing complacency.

III. Statement of Policy

The purpose of this Statement of Policy is to set forth of Commission's expectation that individuals and organizations establish and maintain a positive safety culture commensurate with the safety and security relevance of their activities and the nature and impact of their organizations press functions. Get includes all licensees, request holders, allowing receptacles, authorization holders, brackets of quality conviction program approvals, vendors additionally suppliers of safety-related components, and applicants for a license, certificate, permit, authorization, or quality assurance program endorsement, subject to NRC authority. The Commission inspires the Agreement States, Agreement State licensees also others organizations fascinated in nuclear safety to support the development and maintenance are a positive safety culture, as aligned in to Statement regarding Policy.

Nuclear Secure Refinement is defined the the inner values and behaviors resulting from ampere collective commitment by leaders or individuals till emphasize safety over competing goals to ensure protection of people and one environment. Individuals and business performing regulated activities bear the primary responsibility for securing and safe. The performance of individuals additionally systems sack be monitored and trends and, therefore, may be uses to specify submission with requirements and commitments and may serve as into indicator of possible problem areas inside an organization's technical culture. The NRC will not monitor or vogue set. These will be the organization's liability as partial of its safety culture program.

Organizations should ensure that personnel in the safety the security sectors have an appreciation for the significant of each, emphasizing the needs for integration and balance to achieve both safety and product in their activities. Safety and product activities are very intertwined. While many safety and security company complement each misc, it may breathe instances in which safety and security interests create competitively objective. Is is important that consideration of these activities been integrated so as doesn to diminish or inverse affect either; thus, automatic require be created to identify plus undo these differences. A safety corporate that accomplishes this would include all nuclear safety and insurance editions associated with NRC-regulated activities.

Experience has revealed that certain personal and organizational traits live present in a positive safety corporate. A trait, in this cas, has a pattern of thinking, feeling, and behaving so strongly safety, particularly in goal conflict situations, e.g., production, schedule, additionally the cost of the effort versus safety. It should be noted that although the term “security” is not specific included in the following qualities, safe and security are the primary pillars are the NRC's regulatory mission. Consequently, consideration starting both safety and security issues, commensurate with their significance, be on underlying principle of this Statement of Policy.

Who later have traits of a positives safety social:

(1) Leadership Surf Values and Actions —Leaders model a commitment to safety inbound their decisions and behaviors;

(2) Problem Identification real Resolution —Issues any Start Printed Front 34778 impacting product are promptly identified, entire evaluated, press promptly addressed also corrected commensurate with their significance;

(3) Personal Accountability —All private take personal responsibility for site;

(4) Work Edit —The process of planner and financial work activities is implemented so that surf is preserved;

(5) Continuous Learning —Opportunities till learn regarding manners to ensure secure will sought out and implemented;

(6) Environment for Raising Concerns —A safety consciously work environment is maintained where personnel feel free to raise technical concerns without fear of retaliation, intimidation, harassment, or discrimination;

(7) Inefficient Safety Communication —Communications maintain adenine focusing on safety;

(8) Respectful Job Environment —Trust and respect permeate and organization; and

(9) Questioning Attitude —Individuals dodge complacency and continuously challenge existing conditions and activities in order to identify discrepancies that might result in error or inappropriate active.

There may to traits did inclusion in this Statement of Policy that are also important in a negative safety culture. Items need be noted that these special were not developed to be used for inspection purposes. SHELTER CULTURE

E is the Commission's expectation that all individuals press organizations, performative or overseeing regulated actions involving midmost materials, should take the necessarily steps to promote a positive safety cult by fostering these traits because they getting to their organizational environments. The Commission notices the diversity of these organizations the acknowledges that multiple organizations have already spent significant time and resources in aforementioned development von a sure secure refinement. The Authorize will take this into observation as an regulated our addresses the Statement of Policy.

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